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Drawing on his recently published Independent Review of Fraud Offences, Jonathan Fisher KC outlines the association between organised criminal activity and digital fraud. He discusses the way forward as the UK is poised to lead the G20 in the coming year
The tsunami of digitally enabled fraud currently impacting the UK will not be reduced, let alone resolved, without much greater international cooperation between enforcement authorities and countries which currently provide havens for the malign activities of organised crime groups engaging in highly profitable digital fraud to the prejudice of its citizens. Efforts made in recent years by the UK enforcement authorities have been well meaning and pointed in the right direction, but they have barely landed a punch on the organised criminal fraternity and those who support them. Much more needs to be done and different levers need to be pulled. Although increasing the number of fraud prosecutions in the UK is an obvious response, it will not solve the problem. Smarter measures are required, directed at prevention as much as enforcement.
The scale of the problem is large and deep-rooted. An estimated 70% of fraud has an international element with 30% being primarily committed by overseas offenders. During the course of my Independent Review on Fraud Offences, I discovered the prevalence of fraud is inextricably tied to the operations of transnational organised criminal gangs who have transformed fraud from the actions of a handful of rogues to an industrial scale model, replete with call-centres, online forums, and even fraud academies. I learnt that one factor contributing to the growth of fraud has been the inadequate and patchwork response of countries to this growing global threat. Failures range from lacking law-enforcement capacity, outdated technology, and siloed approaches. This has created an environment in which fraudsters can operate internationally with relative impunity, exploiting regulatory gaps and jurisdictional fragmentation to avoid detection and accountability.
I also received material from a law enforcement authority that, in India for example, the technology by organised criminal gangs remains a significant barrier for law enforcement. Scam centres in India are utilising a range of technology to avoid detection, automate and scale up their operations and to identify potential targets. The technology weaponised includes Voice over Internet Protocol (VoIP) servers, remote access tools (RATs), robot-diallers, and victim call lists which can be purchased through the dark web. After Indian law enforcement attempted to crackdown on larger scam centres, small-scale operations soon emerged.
A further assessment of fraud in Nigeria highlighted that law enforcement requests are often very slow in the way they are processed, partly due to a lack of comparable online and digital systems throughout the Nigerian public sector. Instead, records are often maintained on paper and held locally, leaving space for organised criminals to thrive while important evidence remains buried in an archive, if retained at all.
Yet to combat digital fraud, it is essential that governments, regulators, and industry leaders remain agile and forward-looking in their approach to technological innovation. This means not only investing in advanced tools to counter fraud, but also fostering collaboration across sectors to share intelligence, develop best practices and anticipate emerging threats. Without a coordinated and proactive response, the technological advantage will continue to favour fraudsters, leaving individuals, businesses and institutions increasingly vulnerable. Governments need to fight fire with fire, using the same digital advancements employed by fraudsters but in a more noble cause.
Tied to this growth of technology is the development of social media, which has radically transformed society, enabling individuals from across the globe to connect with one another and often to find community. While social media can play a powerful and positive role in supporting communities and independent journalism, it is increasingly being exploited by fraudsters to devise new schemes, identify potential victims and conduct targeted campaigns. In an earlier section of the Review, I set out the case for extending corporate criminal liability to social media companies and stressed the need for these platforms to moderate user generated content.
Addressing the misuse of these platforms by fraudsters therefore requires not only robust domestic regulation but also coordinated international efforts to establish shared principles of accountability and digital governance.
In the coming year the UK is well placed to lead international efforts to build a global consensus on fraud. In addition to measures designed to tackle fiscal leakage, I have suggested in my Review a small number of key recommendations the UK could adopt, and persuade other jurisdictions to adopt, which would strengthen the use of international tools in the fight against fraud.
First, the UK should improve the pursuit of international fraud offenders by (a) increasing liaison magistrates and liaison prosecutors in foreign jurisdictions to facilitate Letters of Request and Extradition, and by (b) ensuring the CPS provides sufficient training for prosecutors on how and when to use international Letters of Request to obtain investigative material and facilitate its introduction into evidence in subsequent legal proceedings.
Secondly, the UK should use, and encourage other jurisdictions to use, trade agreements and Memorandum of Understandings to promote international law enforcement cooperation on evidence gathering, asset recovery, and extradition in fraud and other financial crime cases.
Thirdly, the UK has a once-in-a-generation opportunity, which it should take, to assume the lead in developing a protocol to the International Convention for the Prevention of Cybercrime, ensuring Fraud is recognised as a priority.
This would embed fraud within the architecture of global cybercrime enforcement, strengthen cross-border cooperation, and provide a clear legal basis for intelligence sharing among authorities and joint disruption operations. Without such a protocol, fraud risks remaining a secondary concern, despite its scale, systemic impact and increasing convergence with cyber-enabled crime.
Fourthly, where appropriate to do so, the UK should designate Foreign Nationals Orchestrating Transnational Fraud for Targeted Sanctions. This measure would enable the UK to impose asset freezes, travel bans, and other penalties on individuals based overseas who coordinate or profit from large-scale fraud operations targeting UK citizens.
Fifthly, the UK should, alongside other jurisdictions, introduce a system for withholding UK visas from foreign nationals linked to fraud against UK victims, in line with existing powers under the Immigration Rules and the Sanctions and Anti-Money Laundering Act 2018. This would complement the government’s use of targeted immigration sanctions against individuals involved in transnational criminal activity.
The UK is set to host the G20 summit in 2027. While these summits do not always result in new laws, they provide an opportunity for countries to publish communiqués and ministerial statements which each G20 member may, or may not, implement, depending on the nature of the matter at hand. Certainly, the G20 summit provides an opportunity for the UK to raise the profile of digitally enabled fraud and responses, as a good example of the extent of the UK’s soft power and ability to bring pressure to bear on matters affecting law and order as well as shaping economic policy. Back in November 2025 the Starmer government announced that the UK will use the summit ‘to drive global growth, seize the global agenda and reinforce global stability – essential for working people in the UK’.
Plainly, measures to combat fraud and reduce its incidence domestically and internationally will form part of the agenda.
Jonathan Fisher KC practises at Red Lion Chambers London. Additionally, he is a Senior Fellow (and Visiting Professor in Practice) at LSE. In October 2023, the Home Office appointed Jonathan to act as Independent Reviewer in Disclosure and Fraud Offences. This was a part-time role which Jonathan conducted from Chambers.
The tsunami of digitally enabled fraud currently impacting the UK will not be reduced, let alone resolved, without much greater international cooperation between enforcement authorities and countries which currently provide havens for the malign activities of organised crime groups engaging in highly profitable digital fraud to the prejudice of its citizens. Efforts made in recent years by the UK enforcement authorities have been well meaning and pointed in the right direction, but they have barely landed a punch on the organised criminal fraternity and those who support them. Much more needs to be done and different levers need to be pulled. Although increasing the number of fraud prosecutions in the UK is an obvious response, it will not solve the problem. Smarter measures are required, directed at prevention as much as enforcement.
The scale of the problem is large and deep-rooted. An estimated 70% of fraud has an international element with 30% being primarily committed by overseas offenders. During the course of my Independent Review on Fraud Offences, I discovered the prevalence of fraud is inextricably tied to the operations of transnational organised criminal gangs who have transformed fraud from the actions of a handful of rogues to an industrial scale model, replete with call-centres, online forums, and even fraud academies. I learnt that one factor contributing to the growth of fraud has been the inadequate and patchwork response of countries to this growing global threat. Failures range from lacking law-enforcement capacity, outdated technology, and siloed approaches. This has created an environment in which fraudsters can operate internationally with relative impunity, exploiting regulatory gaps and jurisdictional fragmentation to avoid detection and accountability.
I also received material from a law enforcement authority that, in India for example, the technology by organised criminal gangs remains a significant barrier for law enforcement. Scam centres in India are utilising a range of technology to avoid detection, automate and scale up their operations and to identify potential targets. The technology weaponised includes Voice over Internet Protocol (VoIP) servers, remote access tools (RATs), robot-diallers, and victim call lists which can be purchased through the dark web. After Indian law enforcement attempted to crackdown on larger scam centres, small-scale operations soon emerged.
A further assessment of fraud in Nigeria highlighted that law enforcement requests are often very slow in the way they are processed, partly due to a lack of comparable online and digital systems throughout the Nigerian public sector. Instead, records are often maintained on paper and held locally, leaving space for organised criminals to thrive while important evidence remains buried in an archive, if retained at all.
Yet to combat digital fraud, it is essential that governments, regulators, and industry leaders remain agile and forward-looking in their approach to technological innovation. This means not only investing in advanced tools to counter fraud, but also fostering collaboration across sectors to share intelligence, develop best practices and anticipate emerging threats. Without a coordinated and proactive response, the technological advantage will continue to favour fraudsters, leaving individuals, businesses and institutions increasingly vulnerable. Governments need to fight fire with fire, using the same digital advancements employed by fraudsters but in a more noble cause.
Tied to this growth of technology is the development of social media, which has radically transformed society, enabling individuals from across the globe to connect with one another and often to find community. While social media can play a powerful and positive role in supporting communities and independent journalism, it is increasingly being exploited by fraudsters to devise new schemes, identify potential victims and conduct targeted campaigns. In an earlier section of the Review, I set out the case for extending corporate criminal liability to social media companies and stressed the need for these platforms to moderate user generated content.
Addressing the misuse of these platforms by fraudsters therefore requires not only robust domestic regulation but also coordinated international efforts to establish shared principles of accountability and digital governance.
In the coming year the UK is well placed to lead international efforts to build a global consensus on fraud. In addition to measures designed to tackle fiscal leakage, I have suggested in my Review a small number of key recommendations the UK could adopt, and persuade other jurisdictions to adopt, which would strengthen the use of international tools in the fight against fraud.
First, the UK should improve the pursuit of international fraud offenders by (a) increasing liaison magistrates and liaison prosecutors in foreign jurisdictions to facilitate Letters of Request and Extradition, and by (b) ensuring the CPS provides sufficient training for prosecutors on how and when to use international Letters of Request to obtain investigative material and facilitate its introduction into evidence in subsequent legal proceedings.
Secondly, the UK should use, and encourage other jurisdictions to use, trade agreements and Memorandum of Understandings to promote international law enforcement cooperation on evidence gathering, asset recovery, and extradition in fraud and other financial crime cases.
Thirdly, the UK has a once-in-a-generation opportunity, which it should take, to assume the lead in developing a protocol to the International Convention for the Prevention of Cybercrime, ensuring Fraud is recognised as a priority.
This would embed fraud within the architecture of global cybercrime enforcement, strengthen cross-border cooperation, and provide a clear legal basis for intelligence sharing among authorities and joint disruption operations. Without such a protocol, fraud risks remaining a secondary concern, despite its scale, systemic impact and increasing convergence with cyber-enabled crime.
Fourthly, where appropriate to do so, the UK should designate Foreign Nationals Orchestrating Transnational Fraud for Targeted Sanctions. This measure would enable the UK to impose asset freezes, travel bans, and other penalties on individuals based overseas who coordinate or profit from large-scale fraud operations targeting UK citizens.
Fifthly, the UK should, alongside other jurisdictions, introduce a system for withholding UK visas from foreign nationals linked to fraud against UK victims, in line with existing powers under the Immigration Rules and the Sanctions and Anti-Money Laundering Act 2018. This would complement the government’s use of targeted immigration sanctions against individuals involved in transnational criminal activity.
The UK is set to host the G20 summit in 2027. While these summits do not always result in new laws, they provide an opportunity for countries to publish communiqués and ministerial statements which each G20 member may, or may not, implement, depending on the nature of the matter at hand. Certainly, the G20 summit provides an opportunity for the UK to raise the profile of digitally enabled fraud and responses, as a good example of the extent of the UK’s soft power and ability to bring pressure to bear on matters affecting law and order as well as shaping economic policy. Back in November 2025 the Starmer government announced that the UK will use the summit ‘to drive global growth, seize the global agenda and reinforce global stability – essential for working people in the UK’.
Plainly, measures to combat fraud and reduce its incidence domestically and internationally will form part of the agenda.
Drawing on his recently published Independent Review of Fraud Offences, Jonathan Fisher KC outlines the association between organised criminal activity and digital fraud. He discusses the way forward as the UK is poised to lead the G20 in the coming year
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